IR 05000416/1992020
| ML20126E289 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 12/15/1992 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Cottle W ENTERGY OPERATIONS, INC. |
| References | |
| NUDOCS 9212290083 | |
| Download: ML20126E289 (29) | |
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E i 5 1992 f J Docket No. 50-416 License No. NPF-29 Entergy Operations, In ATTH: Mr. W. T. Cottle, Vice President Nuclear Operations - Grand Gulf P. O. Box 756 Port Gibson, MS 39150 Gentlenen:
SUBJECT: SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (NRC INSPECTION REPORT NO. 50-416/92-20)
This refers to the NRC's Systematic Assessment of Licensee Performance (SALP) ;
Report for your Grand Gulf facility which was sent to you on November 5,1992; our meeting on November 13, 1992; and your SALP response letter of December 2, >
1992, in your letter, you indicated that the portion of the SALP report discussing operator training, does not make a clear distinction between comments associated with the requalification training program and comments tied to the initial training program. We agree that the section does not make a clear-distinction and that was by design. The phrase noted in your letter was intended to refer to both initial and requelification since similar weaknesses were noted in both programs. We elected not to change the SALP, therefore, the Initial SALP becomes the Final SAL As indicated in my November 5,1992 letter to you, Grand Gulf's attainment of superior performance in the majority of the SALP functional areas-in successive SALP periads is commendable. Your res)onse makes it clear that you and your staff inte'd to continue.to strengthen tiose areas where challenges were identified, saeking continuous improvement that should lead to further sustained superio' performanc I was pleased t , seu many local officials in attendance at the SALP presentatica. I w * also pleased with the participation by you and your staff at the subsequent mting with the local officials to reaffirm the NRC's role, as well as address any questions or items of mutual interes In accordance with Section 2.790 of the NRC's " Rules of Practice," a copy of this letter and it's enclosures will be placed in the F Public Document Roo PDR ADOCK 05000416 G PDR s(
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DEC 151992
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Entergy Operations, In No reply to this letter is required. However, should you have any questions, I would be pleased to discuss them with yo
Sincerely,
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original signeo by:
stewart D. tbneter Stewart D. Ebneter .,
Regional Administrator
Enclosures:
, Meeting Summary 4 SALP Presentation Slides , Entergy Letter dated December 2, 1992
REGION ll ORGANIZATION
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0FFICE OF THE ADMINISTRATOR ADMINISTRATOR S. EBNETER ,
DEPUTY L.REYES i
DIVISION OF DIVISION OF DIVISION OF REACTOR SAFETY RADIATION SAFETY REACTOR PROJECTS AND SAFEGUARDS i
D PlffY (V CANT) DEP B 0P J. JOHNSO -. _ _
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DIVISION OF REACTOR PROJECTS
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ORGANIZATION DIVISION OF REACTOR PROJECTS I DIR. E. MERSCHOFF DEPUTY J. JOHNSON I
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REACTOR PROJECTS BRANCH N ( CHIEF D. VERRELLI l
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I I I PROJECTS SECTION PROJECTS SECTION NO.1 A N O.1B CHIEF CHIEF H. CHRISTENSEN F. CANTRELL
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BRUNSWICK FARLEY ( ROBINSON HARRIS GRAND GULF R. BERNHARD SUMMER .
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NRR ORGANIZATION OFFICE OF NUCLEAR REACTOR R EG ULATION DIR. T. MURLEY t
ASSOC. DIRECTOR ASSOC. DIRECTOR ASSOC DIRECTOR FOR PROJECTS "^ ^"
FOR INSPECTION AND gggCTORS A D J. PARTLOW TECHNICAL ASSESSMENT LICENSE RENEWAL
DIVISION OF REACTOFi PROJECTS lilllV/V P
J. ROE, DIR, Ill/lVN M.VIRGILLO, ASST DIR. IVN J. LARKINS, IV-1 R OCONNER
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PERFORMANCE ANALYSIS AREAS :
FOR OPERATING REAQTORS
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A. PLANT OPERATIONS B. RADIOLOGICAL CONTROLS C. MAINTENANCE / SURVEILLANCE D. EMERGENCY PREPAREDNESS ,
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G. SAFETY ASSESSMENT / QUALITY:
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VERIFICATION
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AREA PERFORMANCE CATEGORY 1 l
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'l LICENSEE MANAGEMENT ATTENTION TO AND INVOLVEMENT IN NUCLEAR SAFETY OR SAFEGUARDS ACTIVITIES RESULTED IN A SUPERIOR LEVEL OF PERFORMANC NRC WILL CONSIDER REDUCED LEVELS OF INSPECTION EFFOR .
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i AREA PERFORMANCE CATEGORY 2
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OR SAFEGUARDS ACTIVITIES RESULTED IN A GOOD LEVEL OF PERFORMANC NRC WILL CONSIDER MAINTAINING .
NORMAL LEVELS OF INSPECTION .
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AREA PERFe 1 A E C/ ; EGORY 3 LICENSEE MANAGEMENT ATTENTION TO AND INVOLVEMENT IN NUCLEAR SAFETY OR SAFEGuaADS ACTIVITIES HESULTED IN AN ACCEPTABLE LEVEL OF PERFORMANCE; HOWEVER, BECAUSE OF THE NRC'S CONCERN THAT A DECREASE IN PERFORMANCE MAY APPROACH OR REACH AN UNACCEPTABLE
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LEVEL, NRC WILL CONSIDER INCREASED LEVELS OF INSPECTION EFFOR I
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EVAL ATleN ITE l>
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1. MANAGEMENT INVOLVEMENT AND CONTROL IN ASSURING QUALITY 2. APPROACH TO IDENTIFICATION AND RESOLUTION OF TECHNICAL ISSUES FROM A SAFETY STANDP0lNT 3. ENFORCEMENT HISTORY
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- 4. REPORTING, ANALYSIS AND CORRECTIVE ACTION OF REPORTABLE EVENTS 5. STAFFING (INCLUDING MANAGEMENT)
6. TRAINING EFFECTIVENESS AND 4 QUALIFICATION
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OPERATIONS ;
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OVERALL PERFORMANCE IN THE AREA OF OPERATIONS REMAINED EXCELLENT STRENGTHS
- MANAGEMENT INVOLVEMEMT ,
- OPERATOR RESPONSE TO TRANSIENTS
- SHUTDOWN RISK APPLICATION TO OUTAGE MANAGEMENT-
- FIRE PROTECTION
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LCATEGORY 1)
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i CHALLENGES t
- CONTINUE FOCUS ON INATTENTION TO DETAIL
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CONTROLS
(CATEGORY 1)
OVERALL PERFORMANCE IN THE AREA OF RADIOLOGICAL .
COhTROLS REMAINED EXCELLENT STRENGTHS i
- APPROACHES TO DOSE REDUCTION
- CONTROL CONTAMINATED FLOOR SPACE AhD LEAKS -
- HP SUPPORT IN ALL AREAS FOR OUTAGES -
- TRAINING
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RADIOLOGICAL CONTROLS (CATEGORY 1)
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STRENGTHS
- CHEMICAL Ah D RADIO _.OGICAL Ah ALYSIS P90 GRAM (
- COhTROL OF EFFLUENT RELEASES TO ENVIRONMENT CHALLENGES
- VIAlhTAlblNG LOW DOSE FOR N AJOR WORK
= COhTROL PCE'S DURING N AJOR WORK l
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VAINTENANCE/
SURVEILLANCE (CATEGORY 1)
OVERALL PERFORMANCE IN THE AREA OF MAlhTENANCE/
SJRVEILLANE REN AINED EXCELLEhT STRENGTHS
- UAN AGEMEhT lhVOLVEMEhT
= TESTI\ G PROGRAM
= 3LANhlhG MAJOR WO9K
- SYSTEM TRENDING A\ J lEVIEW FOR BEST M AlhTEh AhCE SCHEDULE
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EMERGENCY
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PREPAREDNESS
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OVERALL PERFORMANCE IN THE AREA OF EMERGENCY PREPAREDNESS REMAINED .
EXCELLEh T STRENGTHS
- MANAGEMENT SUPPORT
. COMPREHENSIVE TRAlblNG PROGRAM e USE OF AUDIT FINDlhGS
- WELL STAFFED
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PREPAREDNESS (CATEGORY 1) :
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CHALLENGE
- WAINTAlblhG TIMELY EOF ACTIVATIOh l
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SECURITY (CATEGORY 1)
OVERALL PERFORMAhCE IN THE AREA Or SECURITY REMAlhED EXCELLEhT STRENGTHS
- COOPERATION WITH OTi .dR DEPARTMEh TS
- N AN AGEMENT SUP 3 ORT /
V SIBILITY
- TREhDI\G PROGRAM
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CHALLENGE
- EQUIP V Els T ERRORS /
- AGE OF SYSTEM
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TECHNICAL SUPPORT (CATEGORY 2) ,
OVERALL PERFORVIANCE IN THE AREA OF EhGlhEERIKG/
TECHhlCAL SUPPORT DECLINED STRENGTHS l
- DESIGN EhGlhEER NG SUPPORT
- TRAlblNG OF SYSTEMS L EhGINEERS
- REV EW OUTAGE WORK FOR SHUTDOWh RISK
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ENGINEERING TECHNIAL/ SUPPORT (CATEGORY 2)
(CONT'D)
CHALLENGES
- MAlbTAlblhG SYSTEMS ,
ENGINEERS IN PREVENTATIVE VERSUS REACTIVE MODE l
OPERATOR TRAlhlhG
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SAFETY ASSESSMENT /
QUALITY VERIFICATION (CATEGORY 1)
OVERALL PERFORMAhCE IN THE AREA OF SAFETY ASSESSMEN T/ QUALITY VERIFICATIOh WAS EXCE_ LENT STRENGTHS
- GOO] PRIOR PLAhhIhG
- WELL QUALIFIED STAF
- RECOGhlTIOh OF PROBLENS
- SAFETY ASSESSVENT/
AUDIT PROGRAM
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QUALITY VERIFICATION (CATEGORY 1)
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STRENGTHS
- MANAGEMENT SUPPORT FOR SAFETY FOCUS
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CHALLENGES
- COhTINUE MAh AGEMENT
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FOCUS ON PRIOR L PLANNih G l
- CONTINUE PERFORMAhCE BASE AUDITS L
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W. T. Cottie December 2,1992
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U. S. Nuclear Regulatory Commission Mail Station PI 137 Washington, D.C. 20555 Attention: Document Control Desk Subject: Grand GulfNuclear Station Unit 1 Docket No. 50-416 License No. NPF-29 Response to the 1992 Initial SALP Report GNRO: 92/00147 '
Gentlemen:
We are pleased to respond to the 1992 initial SALP report for Grand Gulf.-
In preparing our comments we were gratified to note the close convergence between the NRC's assessment of our strengths and challenges, and the results of our own assessment Reaching a shared viewpoint is something that we can all be proud of, and is a tribute to the quality of our communications and the constmetive approach taken by the NRC in the-SALP proces The major challenges for the future are clear - scram reduction and continuous improvement. ;We believe that we have the blueprint, the motivation and the top notch personnel necessary to get us ther Yours truly,
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e.e r-'amars:::,
WTC/MJM/be attachments: - Response to the 1992 Initial SALP Report -
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ENTERGY OPERATIONS COMMENTS 19921NITIAL SALP REPORT Introduction As Mr. Ebneter indicated in his remarks on November 13 maintaining a i superior level of performance may be as difficult as getting there in th first place, We are pleased that Grand Gulf per performance recor We have a lot to be proud of this past SALP period including:
. Safe operation and the absence of significant events e Strong performance by all site personnel e Innovative approaches to technical problems e Excellent outage performance , . Strengthening safety culture i
e increased focus on continuous improvement e Good regulatory communications We are particularly proud of our personnel - their commitment to excellence and their continuing enthusiasm for quality performanc i The Process Management Challenge l In retrospect, each SALP period has a dominant theme and challenge th drives growth of the Grand Gulf organization. While we continued to maintain and build upon our past successes, this SALP period presented ! fresh challenges in terms of persistent problems with hardware-related scrams that, initially, were unresponsive to our standard approach to '
problem solving. Developing long-term solutions to these problems ; l required us to focus as much attention on the areas of process and i organization as we had given to the technical issues involved.
! Consequently, this SALP period has been characterized by our growing i
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. recognition that process management is as important, if not more so, than issue managemen We found that seemingly unrelated hardware scrams had hidden commonalities consisting of process difficulties and organizational problems. As the SALP period progressed and we became more sophisticated at diagnosing process problems, it became apparent that the underlying causes of hardware scrams also contributed to problems in other areas. As a result, Grand Gulf developed a comprehensive action plan intended, in part, to improve the quality of key site processe Although we are in the early stages of implementation, wo expect this effort (discussed in more deiall below) to pay handsome dividends for the futur Shifting focus from issue management to process management has not been an easy task for us, nor is the process complete. In the course of doing so, however, we believe that we have taken another step towards organizational maturity, and enhanced the traditional strengths of Grand Gulf by developing even stronger bonds of teamwork and common purpos Il Integrated Site Action Plan The Integrated Site Action Plan (ISAP) is a collection of improvement initiatives designed to enhance Grand Gulf performance in the areas of management oversight, interdepartmental processes and people issue The purposes of the plan are:
. To provide site focus on high priority items that are important to the overall success of Grand Gul . To effect a dramatic reduction in scram frequenc . To generato a step increase in the quality of functional site processes and a corresponding increase in management oversight of, and site personnel commitment to, those processes that lead to error-free performanc . To eliminate periodic increases of inattention to detail event .
To ensure all personnel are aware of their responsibilities and ere accountable for their action _ _ , _ _ _ . . , . . - -- -- - - - - - - ^
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' implementation of the plan has begun, with most actions to be complete? _ prior to the next refueling outage. - Although the individual elements of the - 1 ISAP are e4ensive, it is worthwhile to briefly discuss a few of the majo activities.~ *
. Trio-critical systems: A concerted effort is undenway to focus ;
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l attention and resources on systems whose failure could initiate " ' scrams. Root cause evaluation, preventive maintenance, operational evolutions and other activities will be especially focused, or receive enhanced management oversight, when - applied to trip <:ritical systems. In addition, the reliabliity_ centered maintenance schedule is being revised to glia * preference to tripcitical system ..
* Root causamluation And trendina: Ws are in the process o creating a dedicated root cause analysis group _within our Performance & System Engineering department. This group ___
will be responsible for conducting or overseeing root cause evaluations for significant problems, including the failure of trip-critical components and safety-significant events. Similarly, a centralized performance monitoring and trending program will ' be developed within the Quality Programs department. The - "i purpose of this effort is to provide early indication of adverse q trends affecting trip-critical equipment, e Corrective action ersm.m:- The site wide corrective action - d program is being upgraded to increase consistency _ amongst - deficiency identification documents, to emphasize the need for early problem identification and to deliver training to a broad range of site personnel.-- - e Eqhanced self-assessment capabilities: :We are taking a fresh : look at site and departmental goals and performance measures - to ensure proper alignment _with corporate goals on safety, cost - ! and operational' performance. : A site performance monitoring system will .be implemented to synthesize a wide range of, measures into a relatively small set of overall performance : 1 measures.< Additionally,' every site department will perform selected self-assessments to evaluate their key processe The ISAP is dynamickwe' expect the plan to change to accommodate : changing conditions and intend to keep the NRC informed of our
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I SALP Recommendationa in its report, tho' SALP Board made the following recommendation in the area of Engineering /rechnical Suppor Management attention should continue to focus on scram reduction and training of operator Scram reduction had been an area of constant focus during the preceding SALP period and will continue to occupy significant rnanegement attention for the forseeable future, in addition to concentrating resources on furidamental process areas affecting scram rate, as described for the ISAP above, Grand Gulf management continues to address the hardware issues associated with plant trips. Extensive modifications have been made and continue to be made to minimize the potential for further . lightning induced scrams. We continue to pursue feedwater/ condensate,- load shedding and sequencing and other hardware related scram initiators; In some cases, the technical issues we face are complex and - not amenable to easy solutions. But, we are confident that our continued attention to these problems will result in a marked improvement in scram rate for the upcoming SALP period.
p Like scram reduction, operator training commanded serious management - l attention during the last SALP period. Due to decreasing performance on initial and requalification operator examinations, a number of-- l- programmatic improvements were implemented.- Based on _early - L indications from the requalification program we are cautlously optimistic - that the combination of programmatic improvements, new leadership and ! L focused management attention has resulted in a retum to improved-i performance in the training area. However,'_we will continue to stress - the - importanos of operator training and maintain increased management oversight of this critical are We would also like to take this opportunity to clarify a portion of the SALP report. - With respect to operator training, no clear distinction.ls made ' between comments associated with the requalification training program
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and comments tied to the initial training program. In particular, the report L seems to imply that " failure to properly prepare or remediate candidates and lack of instructor certification in technical skills" were contributors to ' weaknesses in the requalification program. We believe that such'. ; problems should properly be attributed to the initial training program.
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- SALP Functional Area Challenges The challenges presented to us by 9 NRC in the November 13 SALP .
meeting coincided with our own assNament of necessary goals for the ' upcoming SALP period.- We agrec, that continued success is dependent, .
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in large measure,'upon satisfying the following objective . Operatione - >
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. Continue focus on Inattention to detail A major focus of the ISAP is personal responsibility and ;
accountability which includes the concepts of attention to detail,. procedural compliance, self-verification, and other_ factors associated with human performance. While conoontrating . renewed effort in these areas, we intend to continue past successful actions such as close tracking of inattention to' detail
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e Housekeeping in inaccessible areas (i.e., RHR & RCIC rooms)'- ' To provide added emphasis, non-licensed operators are conducting tours of the ECCS pump room areas._ .We have assigned responsibility for pump room cleaniness to the - appropriate building operators and management will continue to - , emphasize and check past problem areas. - 8.- Radiological Controla -
L . Maintaining low dose for major work - n Grand Gulf has been very successful in reducing'doso - associated with major work.; We recognize that the NRC's - ' challenge in this case is to maintain our high level of s performance. In addition to continued attention on work L planning activities,~ personal responsibli.ty
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i for dose and similar l-efforts, we are launching a major initiative to reduce plant source terms. _We believe this approach to be a viable means - of significant dose reduction in the futur i- : b p
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. Control PCEs during major work .
The primary contributor to personnel contamination events (PCEs) was determined to be discreet particles from laundered protective clothing.' Accordingly, we have i.nitiated a number of -- actions in conjunction with our laundry contractor to reduce the number of these event Maintenance / Surveillance e Procedural adequacy The weaknesses noted with procedural adequacy occurred during the first half of the previous SALP period and have been successfully addressed. We will continue to trend procedural deficiences along with personnel errors in order to provide early identification of adverse trends, and will continue to discuss tho' trends during periodic management meeting * Work backlog As noted in the SALP report, the work request backlog is on a positive downward trend.- We intend to continue our actions such as reviewing the 10 oldest work orders in weekly. meetings ; with plant mana0ement, and search for additional effective - ways to achieve and maintain a low backlog, e Continue focus on equipment failures contributing to events This issue is related to scram reduction and is discusst under the Integrated Site Action Plan and SALP Recommendations,7 abov . Control contract workers Control of contract workers will be an area of continuing - _ .
- emphasis during this next SALP period. We have implemented -
a number of enhancements in this area including a new training module for new contract employees,' daily briefings for_ contract ; supervision and foremen and monthly reviews by a group of o plant, contract and supervision personnel of work problems E encountered in the field.
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. Maintaining timely EOF activation During the October 1992 NRC graded exercise, the EOF was operational within 45 minutes. The Backup EOF was acti -
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in 66 minutes. A major contributor to improvement in the . activation time was the definition of minimum staffing -
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requirements through administrative proced the activation time for all facilities during future drill Security
. Equipment errorslage of system -
As noted during the SALP exit meeting, we are making good progress on the south perimeter upgrads project and will continue to place emphasis on project completio EngineeringITechnical Support - , ,
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Maintaining systems engineers in preventative versus reactive mode System engineers are central to a number of interdepartmen processes whose inemclencies can seriously impair the ability of the engineer to function regardless of how well the ' p department is organized and managed. ; Consequently, a l primary focus of the integrated Site Action Plan is on ! - improvement of key _ work processes that cross departmenta > l W process changes to reduce workload,- boundaries. -We e4 Improve efficiency and allow system engineers Irwe-M contic; of extemal factors that today adversely affect their function.' .in addition, the Performance & System Engineering department has initiated an effort to re-define the system engineering responsibilities with emphasis on system L prioritization, elimination of non essential work and setting threshholds for acceptable workload.:
. Operator training
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- Discuss'ed under SALP Recommendations, above.
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: .r * -Reduction of scrams due to design related problems i
Discussed under the Integrated Site Action Plan and SALP _ Recommendations, abov . Safety Asseaament/ Quality Verification
. Continue management focus on prior planning Prior planning of regulatory submittals is a distinct advantage ,
for Grand Gulf as well as tho' NRC as it allows early- " identification of problems, rational resource allocation and an ove.all lower dedication of resources.tWe intend to continue . . this practice and have provided the NRR Project Manager with- ' anticipated licensing actions for the current cycle of operation , and the next refueling outage.
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. Continue performance based audits Performance based audits are a centerpiece of the Grand Gulf approach to quality assurance. As the 'Nelue added" of-- -
compilence based audits continues to decline, we expect performance based audits for both the industry and NRC to assume increasing prominence and Imf~ii.nes.-
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